1. AAHRA Scholarship Fund Sponsored Training Combatting Fraud Within Your Housing Authority September 19 – 20, 2018
Click the hyperlink to access the Proposed Rule

2. Agenda What to Expect after an OIG Audit is Issued Types of Reviews
Compliance Reviews
Housing Choice Voucher Reviews
Public Housing Reviews
Other Types of Reviews

3. What to expect after the audit is issued

4. Once the Field Office and the OIG agree on final Management Decisions, a letter is sent to the PHA which will include:
1. Restatement of the Finding
Management Decisions (what the PHA must do to close the finding)
Deliverables (what the PHA must submit to close the finding)
Targeted Action Date (Deadline)
Targeted Action Dates are tracked very closely. These dates cannot be extended unless special permission is given by the OIG. If the dates exceed one year, Congress is notified.

5. The Field Office provides all supporting documentation to the OIG prior to the Final Action Target Date to certify that final actions have been completed and all documentation has been obtained.
The OIG reviews all of the supporting documentation to ensure that the Management Decision requirements have been met.
Final action (closeout) only occurs when the OIG approves all the corrective actions and documents.
If the OIG doesn’t agree, a discussion will be held with the Field Office and the non-approval will be reported to Congress.
Don’t pair us with XYZ Housing Authority, they’re our rivalry in football! (And yes we’ve heard this one before.)

6. Repayment Agreements
The Field Office will be responsible for obtaining a Repayment Agreement.
a. The Agreement must show where the money is coming from and what account it is being paid to.
b. It must be signed by the Chairman, Board of Commissioners, the Executive Director, and HUD.
The Field Office will forward the signed Agreement to the OIG.
If the Agreement is approved, the OIG will adjust the Targeted Action Date to reflect 30 days after the last payment is due.
The PHA will be responsible for providing the Field Office with the appropriate documentation; i.e., copies of checks, deposit slips, bank statements showing deposit was made, etc.

7. Timeline Reminders
1. HUD’s goal for completion of a Final Action is one year from the Management Decision date.
2. For large repayments, the Department’s goal is to repay within not to exceed three years. Typically we would like a one year repayment.
3. HUD is required to submit a semi-annual report to Congress summarizing the activities of the OIG’s Office during the 6 month period ending March 31st and September 30th.
4. Housing Authorities and HUD should strive not to miss any required dates. We want to avoid being included the OIG’s report to Congress with overdue reporting!

8. OIG Audit Questions

9. Types of Reviews

10. Things We Look At When Conducting a Review

11. Risk Assessment Results
Financial
Management
Physical
Governance
Departmental Enforcement Center Reviews
OIG Audits/Investigations
Public Housing Agency Recovery and Sustainability Reviews
Housing Choice Voucher (HCV) Utilization/2 Year Tool

12. Project Based Vouchers (non-RAD)
Section 8 Management Assessment Program (SEMAP) Quality Control Remote Reviews
SEMAP Troubled
Project Based Vouchers (non-RAD)
Rental Assistance Demonstration Program
Public Housing Occupancy
Financial
Audit Findings
Repeat Audit Findings
Quality Assurance Subsystem (QASS)

13. Shortfall Prevention
Quality Assurance Division (QAD)
Interfund Transfers
Compliance with HUD laws, regulations, and requirements
Lead-Based Paint, Mold, and Peeling Paint
Community Service and Self Sufficiency
Environmental Reviews
Fair Housing Issues
Number of Complaints

14. Types of Reviews

15. Compliance Reviews

16. What is a Compliance Review?
A limited review focused on compliance with program requirements and regulations. Performance issues may be noted in thie report but the primary focus is on compliance. Rather than examining anyone area exhaustively, this review touches on multiple areas of compliance to provide the PHA with meaningful feedback for sustained compliance.

17. What Do We Look at

18. Are Board meetings held in accordance with the by-laws
Governance and Management
Board Approved By-Laws
Board Approved Policies
ACOP
Grievance Policy
Procurement Policy
Disposition Policy
Administrative Plan
Financial Policy
Are Board meetings held in accordance with the by-laws
Required number of Commissioners, including Resident Commissioner

19. Timely Submissions
Unaudited
Audited
PHA Plans
SEMAP Certifications
Internal Controls
How often the Executive Director and Board reviews the expenses
Are the bank statement reconciled timely
Are expenses charged to the correct program
Is there adequate insurance in place
Does the PHA accept cash

20. Housing Choice Vouchers
Documentation on file to support the SEMAP Certification
What is the PIC HCV reporting rate
How does HCV leasing compare to the ACC vouchers
Is the HCV HAP within the funding limits
Are HCV funds used only for HCV
Is the PHA reporting accurately in VMS
Are the HAP payments being paid accurately
How is the PHA tracking Lead Based Paint in HCV units/homes
Date of recent Utility Allowance
Is the PHA targeting the statutory requirement of families at

21. extremely low income
Is the PHA following their HCV Admin Plan
Does the PHA have a process to verify income, assets, deductions, etc.
Is the rent calculated correctly
Do HCV units pass HQS inspections; if not, how is this handled
Was rent reasonableness for PHA owned units conducted by HUD-approved independent entity
Are re-exams conducted timely
Is the PHA following its policy for evictions
Are all evictions treated the same

22. Are voucher payment standards set between 90 and 110 percent of the FMR or no greater than 120% (pursuant to HOTMA)
Are any families renting from family members
Has the PHA implemented Family Self-Sufficiency
Does the PHA use the HCV 2 Year Tool or something similar to track their vouchers, leasing potential, funding usage

23. Public Housing What is the PHAs PH PIC data reporting rate
Do payroll records confirm maintenance wage rates are paid in accordance with HUD-determined rates
Is the PHA operating under the Asset Management model
Is the PHA maintaining an adequate reserve level, MENAR
Is the PHA collecting rent
Is the PHA’s Tenants Accounts Receivable high
Is the Procurement Policy consistent with HUD regulations
What about the inventory control system
Does the PHA dispose of equipment or property in accordance with the Disposition Policy

24. When was the last Physical Needs Assessment conducted
Is the PHA meeting the Capital Fund Obligation and Expenditure deadlines
Does the PHA have the required documentation regarding Lead Based Paint
How many Fair Housing complaints has the PHA received
Does the MASS score indicate vacancy problems
Is the PHA following its Board approved ACOP
Does the PHA verify income, assets, deductions, etc.
Is the rent calculated correctly
Are re-exams held timely
Does the PHA have an Evictions Policy

25. Have all PH units that are out of service been approved by HUD
Do the PHAs units occupied agree with PIC
Does the PHA have a Pet Policy
Does the PHA have a No Smoking Policy
How is the PHA handling residents who are non-compliant with the No Smoking Policy

26. Other Types of Reviews

27. Quality Assurance Division (QAD)
VMS Remote/On-Site – the purpose of this review is to determine whether existing VMS data was consistent with housing assistance payment expenses, administrative expenses incurred, and administrative fees eligible from HUD for a specific period of time.
Financial Management Remote/On-Site – the purpose of this review is determine the Unrestricted Net Position (UNP) balance and Restricted Net Position (RNP) balance for a specific period of time, validate and analyze administrative expenses, confirm the availability of cash and/or investments sufficient to support the calculated RNP and UNP, and to ensure proper use of appropriated funds.

28. Rent Reasonableness – The purpose of this review is to assist the agency with Rent Reasonableness analysis and to provide guidance and technical assistance related to improving the Rent Reasonableness process.
SEMAP Remote Quality Control – the purpose of this review is to help ensure the SEMAP rating is an accurate depiction of performance, not to determine how well the PHA did at QC sampling. Indicators 1-7 are included in this review.
Quality Assurance Subsystem (QASS) – The QASS staff of experienced auditors and certified public accountants conduct financial assessment of PHAs and perform a wide variety of ad hoc financial reviews, both

29. internal and externa to the department. These assessment seek to
internal and externa to the department. These assessment seek to pinpoint the causes of financial irregularities, identify risks in new and ongoing programs, and provide realistic recommendations for mitigating financial distress and strengthening internal controls.
Limited Management Review – Very similar to the Compliance Review as to what HUD would look at. Staff will generally provide technical assistance while on-site as well.

30. Types of Reviews Questions

31. THANKS 31
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32. Birmingham Office of Public Housing
Office of Public And Indian Housing Contact Information:
Birmingham Office of Public Housing
Velma Byron, Director
HUD Office: (205)